ML20236R056
| ML20236R056 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/15/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jeffery Wood CENTERIOR ENERGY |
| References | |
| 50-346-98-07, 50-346-98-7, NUDOCS 9807210216 | |
| Download: ML20236R056 (2) | |
See also: IR 05000346/1998007
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July 15, 1998
Mr. John K. Wood
Vice President- Nuclear
Davis-Besse Nuclear Power Station
Centerior Service Company
5501 North State Route 2
Oak Harbor, OH 43449
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-346/98007(DRS))
Dear Mr. Wood:
This will acknowledge receipt of your letter dated June 23,1998, in response to our
letter dated May 26,1998, transmitting a Notice of Violation associated with two examples of a
failure to evaluate the potential radiological hazards and institute appropriate controls prior to
performing work at the Davis-Besse Nuclear Power Station. We have reviewed your corrective
actions and have no further questions at this time. These corrective actions will be examined
during future inspections.
Sincerely,
Original /s/ J. A. Grobe
John A. Grobe, Director
Division of Reactor Safety
Docket No.: 50-346
License No.: NPF-3
Enclosure:
Lir did 6/23/98 from
First Energy to USNRC
See Attached Distribution
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J. Stetz, Senior Vice
President - Nuclear
J. Lash, Plant Manager
J. Freels, Manager
Regulatory Affairs
M. O'Reilly, FirstEnergy
cc w/ encl:
State Liaison Officer, State
of Ohio
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R. Owen, Ohio Department
of Health
C. Glazer, State of Ohio
Public Utilities Commission
Distribution:
Project Mgr., NRR w/ encl
C. Paperiello, Rlli w/enci
J. Caldwell, Rlll w/enci
B. Clayton, Rlli w/ encl
SRI Davis-Besse w/enci
DRP w/ encl
TSS w/enci
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Rill PRR w/enci
PUBLIC IE-01 w/enci
Docket File w/enci
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Davis Besse Nuclear Power Statonn
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.lohn K. Wood
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Voce President - Nuclear
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Docket Number 50-346
License Number NPF-3
Serial Number 1-1163
June 23, 1998
United States Nuclear Regulatory Commission
Document Control Desk
Washington, D.C. 20555-0001
Subject: Response to Inspection Report Number 50-346/97008 (DRS)
Ladies and Gentlemen:
Toledo Edison has received Inspection Report Number IR 50-346TS8007froledo Edison Log
Number 1-3964) and the enclosed Notice of Violation issued on May 26,1998. The violation
involves two examples of a failure to evaluate the potential radiological hazards and institute
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appropriate controls prior to performing work. Toledo Edison provides the attached response to
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the subject violation.
Should you have any questions or require additional information, please contact
Mr. James L. Freels, Manager - Regulatory Affairs, at (419) 321-8466.
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Very truly yours,
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GMW/dle
A. B. Beach, Regional Administrator, NRC Region III
cc:
A. G. Hansen, DB-1 NRC/NRR Project Manager
S. J. Campbell, DB-1 Senior NRC Resident Inspector
Utility Radiological Safety Board
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JUL 0 7 as
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Docket Number 50-346
License Number NPF-3
Serial Number 1-1163
Attachment
Page1
Reply to a Notice of Violation (50-346/98007-01)
Alleced Violation
During an NRC inspection conducted from April 27 through April 30,1998, a violation of NRC
requirements was identified. In accordance with the General Statement of Policy and Procedure
for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be
necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under
the circumstances to evaluate the extent of radiation levels, concentrations or quantities of
radioactive materials, and the potential radiological hazards that could be present.
Pursuant to 10 CFR 20.1003, survey means the evaluation of the radiological conditions and
potential hazards incident to the production, use, transfer, release, disposal, or presence of
radioactive material or other sources of radiation.
10 CFR 20.1201(a)(1)(i) requires, with exceptions not applicable here, that the licensee control
the occupational dose to individual adults to an annual dose limit of 5 rems total effective dose
equivalent.
Contrary to the above, on April 21 and 23,1998, the licensee did not make surveys to assure
compliance with the regulations in 10 CFR 20.1201(a)(1)(i). Specifically:
a.
On April 21,1998, the licensee did not perform surveys to identify the potential for
transient, high dose rates in the annulus area during incore detector movement, prior to
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allowing workers to enter the area. This area had dose rates between 10-20 rem per hour
(contact) on portions of the containment wall during movement of the incore detectors
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(50-346/98007-01a).
b.
On April 23,1998, the licensee failed to evaluate the ALARA controls implemented
during removal of steam generator mirror insulation. Specifically, the radiation
protection technician covering the job, had relaxed the requirements for wearing
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faceshields and for " wetting" the contaminated surface, as discussed in the prejob briefing
or as specified in the Radiation Work Permit, without performing an evaluation of the
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potential radiological consequences. The high contamination levels (50-500 millirad per
hour (smearable)) which existed in the area required that stringent controls be maintained
to prevent the spread of airbome contamination (50-346/98007-01b).
This is a Severity Level IV violation (Supplement IV).
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Docket Number 50-346
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License Number NPF-3
Serial Number 1-1163
Attachment
Page 2
Response to Alleced Violation 50-346/98007-Ola
Reason for Violation
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The annulus between the containment vessel ard the wall of the shield building was not
recognized as an area requiring control as a Locked High Radiation Area during mevement of
activated incore probes. Incore probes are pullen from the shielded incore instrumentation tunnel
into the water-filled incore tank every refueling outage to be cut up for disposa purposes.
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During the most recent refueling outage, there was an incicese in the amount of work performed
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in the annulus due to replacement of radiant energy shields and repainting cf the lour portion of
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the containment vessel in addition to the normally scheduled outage activities. During previous
refueling outages, either personnel were not in the annulus area during cutting of the incore
probes, or incore cutting occurred during transfer ofirradiated fuel from the reactor to the spent
fuel pool. During fuel transfer, the annulus is controlled as a Locked High Radiation Area
because the fuel transfer tubes traverse the annulus. Due to a failure to survey the annulus area
during the separate evolution ofincore cutting, the annulus was not recognized as a potential area
for high radiation levels during the brief period of time the incore probe is not fully shielded.
The high dose rates in the small affected area of the annulus existed for approximately 30
seconds as the incore probe tip traversed the air gap between the shielded incore instrument
tunnel and the water-filled incore tank.
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Corrective Steps Taken and Results Achieved
When the workers' electronic dosimeters alarmed, the workers immediately evacuated the
annulus area between the containment vessel and the wall of the shield building and contacted
Radiation Protection personnel. Radiation Protection personnel responded by performing a
survey of the work location. The initial survey failed to identify the cause of the alarm, so the
workers were allowed to return to the work location with continuous Radiation Protection
coverage. When a second dose rate alarm occuned the workers were promptly evacuated from
the work location. The transient high dose rate was confirmed by the Radiation Protection
technician, and the entire annulus area was controlled as a Locked High Radiation Area for all
incore probe cutting activities. Administrative controls were imposed to prevent use of the
incore cutter without the annulus space being posted as a Locked High Radiation Area. The
maximum dose recorded by any worker's electronic dosimeter was 7 millirem.
Corrective Steps Taken to Avoid Further Violations
The forms associated with procedure DB-HP-04003, Locked High Radiation Area Boundary
Verification, have been revised in accordance with procedure DB-HP-00000, Radiation
Protection Program Administration, to ensure the annulus area between the containment vessel
and the wall of the shield building is controlled as a Locked High Radiation Area during
handling of activated incore probes. No other areas are affected dur'mg handling of activated
incore probes that are not already controlled as a Locked High Radiation Area. In addition,
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Docket Number 50-346
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License Number NPF-3
Serial Number 1-1163
Attachment
Page 3
training will be provided to Radiation Protection personnel on lessons leamed from this incident;
including proper dosimetry alarm response, proper follow-up and investigation of unexpected
dosimetry alarms, and new controls for incore probe handling. This training will be completed
by September 11,1998.
Date When Full Compliance will be Achieved
Full compliance was achieved on April 22,1998, when the annulus area between the
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containment vessel and the wall of the shield building was surveyed during handling of activated
incore probes and posted as a Locked High Radiation Area.
Eesponse to Alleced Violation 50-346/98007-Olb
Reson for Violation
As a result of personnel error by the contract Radiation Protection technician covering the job,
int.dequate contamination control methods were used for insulation removal in an area known to
be highly contaminated beneath the insulation. Controls to minimize the spread of airborne
contamination were discussed during the pre-job briefing, which was attended by the technician.
However, during the actual insulation removal, the technician did not implement the controls
discussed, and did not consult with Toledo Edison Radiation Protection management personnel
prior to relaxing the controls. A contributing factor to this event was that the associated
Radiation Work Permit covered all insulation removal in containment, and the pre-job brief for
this Radiation Work Permit occurred approximately two weeks prior to this specific task. The
insulation workers and thejob supervisor, who also attended the pre-job briefing, followed the
direction of technician instead of following the guidance received from Radiation Protection
management during the briefing.
Corrective Stens Taken and Results Achieved
The contract Radiation Protection technician who erroneously relaxed the contamination control
controls was counseled regarding the event and was reassigned to a different area of the plant for
the remainder of the refueling outage. The workers were decontaminated, and whole body
counts performed to confinn that any intake of radioactive material was significantly below
regulatory limits. A discussion was conducted between Toledo Edison Radiation Protection
management personnel, the insulation workers, and the job supervisor regarding the event to
reaffirm the expectations regarding compliance with pre-job instructions. A detailed
decontamination effort was planned and executed to correct the high contamination levels that
resulted from the insulation removal from the east steam generator in order to recover the
immediate work area affected. Increased supervisory oversight of further insulation jobs was
provided to ensure proper contamination control methods were taken. No further contamination
control incidents related to insulation removal occurred during the remainder of the outage.
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Docket Number 50-346
License Number NPF-3
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Serial Number 1-1163
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Attachment
Page 4
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Corrective Steos Taken to Avoid Further Violations
Additional controls will be established for removal ofinsulation from the affected area of the
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east steam generator. A special Radiation Work Permit with a specific brief to keep personnel
dose "As Low As Reasonably Achievable"(ALARA) for this particular area plus an additional
control to contact the duty Radiation Protection Manager prior to insulation removal will be
utilized to ensure proper controls. These actions will be captured in the Radiation Protection
Outage Critique for incorporation into the Radiation Protection plans for the next refueling
outage. Additionally, training will be provided to Radiation Protection personnel involving the
timeliness of pre-job briefs, management expectations regarding compliance with pre-job
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instructions, and the process for documenting changes to Radiation Work Permit requirements.
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This training will be completed by September 11,1998.
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Date When Full Compliance will be Achieved
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Full compliance was achieved on April 25,1998, when controls were implemented to prevent
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further spread of radioactive contamination associated with the east steam generator insulation.
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